U.S. Appeals Court: PRISONER ACCOUNTS.

Washlefske v. Winston, 234 F.3d 179 (4th Cir. 2000). A state prisoner brought a pro se action under [sections] 1983 alleging that prison officials took his property without just compensation when they expended the interest earned from his prison accounts for the general benefit of inmates. The district court granted summary judgment for the defendants and the prisoner appealed. The appeals court affirmed on other grounds, finding that the prisoner was not deprived of any property for the purposes of a Takings Clause analysis. The appeals court noted that the prisoners claim that he had a property interest in the interest earned on his prison accounts, and that the state...